2024 Filings at the Public Service Commission

ACE NY actively participates in proceedings at the Public Service Commission (PSC) to advocate for the clean energy policies that New York needs to grow business opportunities for renewable energy and energy efficiency businesses.


  • ZERO EMISSIONS DEFINITION

    Comments on Order Initiating Process Regarding Zero Emissions Target. Filed by ACE NY and United in Case 15-E-0203, February 20, 2024.

2023 Filings at the Public Service Commission

ACE NY actively participates in proceedings at the Public Service Commission (PSC) to advocate for the clean energy policies that New York needs to grow business opportunities for renewable energy and energy efficiency businesses.


  • ZERO EMISSIONS DEFINITION

    Comments on Order Initiating Process Regarding Zero Emissions Target. Filed by ACE NY and United in Case 15-E-0203, February 20, 2024.

  • ENERGY STORAGE

    Comments on the Draft Supplemental Generic Environmental Impact Statement related to NY’s 6 GW Energy Storage Roadmap: Policy Options for Continued Growth in Energy Storage. Filed by ACE NY, NY-BEST and SEIA in Case 18-E-0130, October 27, 2023.

  • CAPACITY ACCREDITATION

    Comments on NYSERDA’s Petition Regarding Adjustment to Index REC and Index OREC Formulas for New Capacity Accreditation Rules. Filed by ACE NY in Case 15-E-0203, October 10, 2023.

  • ENERGY DATA RESOURCE

    Comments on the NYSERDA’S Integrated Energy Data Resource Program Phase 2 Proposal by ACE NY and United in Case 20-M-0082, October 16, 2023

  • ZERO EMISSIONS DEFINITION

    Comments on Order Initiating Process Regarding Zero Emissions Target. Filed by ACE NY and United in Case 15-E-0203, August 16, 2023.

  • EV CHARGING

    Joint Comments on the Joint Utilities Electric Vehicle Load Management Technology Incentive Program. Filed by ACE NY and United in Case 22-E-0236, June 6, 2022.

  • DISTRIBUTED ENERGY RESOURCES

    Reply Comments on the Public Service Staff Whitepaper Regarding Marginal Cost of Service Studies. Filed by ACE NY, NY BEST, NYSEIA, United, CCSA, SEIA and 10 other companies in Case 19-E-0283, August 18, 2023.

  • DISTRIBUTED ENERGY RESOURCES

    Comments on the Public Service Staff Whitepaper Regarding Marginal Cost of Service Studies. Filed by ACE NY, NY BEST, NYSEIA, United, CCSA, SEIA and 10 other companies in Case 19-E-0283, July 20, 2023.

  • DISTRIBUTED ENERGY RESOURCES

    Comments on the Department of Public Service State proposal on applying the Customer Benefit Contribution (CBC). Filed by ACE NY, United, and SEIA in Case 15-E-0751, July 17, 2023.

  • MEDIUM- AND HEAVY-DUTY EV CHARGING

    Reply Comments on the Order Instituting Proceeding and Soliciting Comments in the Proceeding to Address the Electrification Needs of the State’s Medium- and Heavy-Duty Electric Vehicle Sector. Filed by ACE NY and United in Case 23-E-0700, June 26, 2023.

  • INFLATION IMPACTS

    Petition to Address Post COVID-19 Impacts on Tier 1 Renewable Development Economics and Contract Consideration. Filed by ACE NY in Case 15-E-0302, June 7, 2023.

  • MEDIUM- AND HEAVY-DUTY EV CHARGING

    Comments on the Order Instituting Proceeding and Soliciting Comments in the Proceeding to Address the Electrification Needs of the State’s Medium- and Heavy-Duty Electric Vehicle Sector. Filed by ACE NY and United in Case 23-E-0700, June 5, 2023.

  • EV CHARGING MAKE-READY

    Supplemental Comments on the Electric Vehicle Make-Ready Program. Midpoint Review and Recommendations Whitepaper. Filed by ACE NY in Case 18-E-0138, May 15, 2023.

  • EV CHARGING MAKE-READY

    Comments on the Electric Vehicle Make-Ready Program. Midpoint Review and Recommendations Whitepaper. Filed by ACE NY and United in Case 18-E-0138, May 15, 2023.

  • STANDBY RATES

    Comments on the Staff Proposal to Extend and Modify Standby Rate Exemptions. Filed by ACE NY, United, and NY-BEST in Case 19-E-0079, April 24, 2023.

  • ENERGY STORAGE

    Joint reply comments on the NY 6 GW Energy Storage Roadmap: Policy Options for Continued Growth in Energy Storage. Filed by ACE NY, NY-BEST, Advanced Energy United, and SEIA in Case 18-E-0130, April 17, 2023.

  • DISTRIBUTED SOLAR

    Comments on the NY Sun Program – Mid-Point Review Whitepaper. Filed by ACE NY, SEIA, NYSEIA, and CCSA in Case 21-E-0629, April 10, 2023.

  • TRANSMISSION

    Comments on the utilities’ revised Coordinated Grid Planning Process. Filed by ACE NY, Advanced Energy United, American Clean Power, the New York Offshore Wind Alliance, and NRDC in Case 20-E-0197, March 27, 2023.

  • ENERGY EFFICIENCY

    Comments on the Staff Energy Efficiency and Building Electrification Report. Filed by ACE NY and United in Case 18-M-0084, March 27, 2023.

  • DISTRIBUTED ENERGY RESOURCES

    Comments on the Proposed Commission Guidance for Electric Utilities 2023 DSIP Update Filings. Filed by ACE NY and United in Case 16-M-0411, March 27, 2023.

  • ENERGY STORAGE

    Comments on NY’s 6 GW Energy Storage Roadmap: Policy Options for Continued Growth in Energy Storage. Filed by ACE NY, United, ACP, and SEIA in Case 18-E-0130, March 20, 2023.

  • TRANSMISSION

    Comments on Implementation of the Transmission Portions of the Accelerated Renewable Energy Growth and Community Benefit Act. Filed by ACE NY, United, NYOWA, and NRDC in Case 20-E-0197, February 28, 2023.

  • UTILITY DATA SHARING

    Comments on the Joint Utilities’ Petition Seeking Commission Direction Regarding the Direct Sharing of Protected Customer Data with the Integrated Energy Data Resource Platform Administrator by ACE NY and United in Case 20-M-0082, February 28, 2023.

  • TRANSMISSION

    Comments requesting PSC to Declare a Public Policy Transmission Need supporting cost-effective integration of land-based renewables in upstate NY. Filed by ACE NY and United in Case 22-E-0633, February 21, 2023.

  • TRANSMISSION

    Comments requesting PSC to Declare a Public Policy Transmission Need supporting approximately 6,000 MW of OSW. Filed by ACE NY and NYOWA in Case 22-E-0633, February 21, 2023.

  • NYSERDA CES MODIFICATION

    Comments on NYSERDA’s Petition Regarding Modification of the Clean Energy Standard to Transition from a Defined Percentage Obligation to a Load Share Obligation. Filed by ACE NY and United in Case 15-E-0302 and Case 15-E-0751, February 6, 2023.

  • DER TARIFFS

    Comments on the proposed utility tariff changes in the Matter of The Federal Energy Regulatory Commission Order Nos. 2222 and 841, to Modify Rules Related to Distributed Energy Resources. Filed by ACE NY and United in Case 22-E-0549, January 23, 2023.

2022 Filings at the Public Service Commission

ACE NY actively participates in proceedings at the Public Service Commission (PSC) to advocate for the clean energy policies that New York needs to grow business opportunities for renewable energy and energy efficiency businesses.


  • TRANSMISSION PLANNING

    Comments on Case 20-E-0197 -- Proceeding on Motion of the Commission to Implement Transmission Planning Pursuant to the Accelerated Renewable Energy Growth and Community Benefit Act

  • TRANSMISSION PLANNING

    Comments on Case 20-E-0197 -- Proceeding on Motion of the Commission to Implement Transmission Planning Pursuant to the Accelerated Renewable Energy Growth and Community Benefit Act

  • TRANSMISSION

    Comments urging PSC and NYISO to proceed to selection of transmission project to address Long Island Public Policy Transmission Needs in Docket 20-E-0497 - In the Matter of New York Independent System Operator, Inc.’s Proposed Public Policy Transmission Needs for Consideration for 2020, November 21, 2022.

  • EV CHARGING

    Comments on Make Ready Midpoint Review by ACE NY and AEE in Case 18-E-0138 - Proceeding on Motion of the Commission regarding Electric Vehicle Supply and Infrastructure, October 4, 2022.

  • NYSERDA WORKFORCE

    Letter of Support for NYSERDA’s Petition on Proposed Year 2023 Clean Energy Standard Funding and Reconciliation of Year 2021 Administrative Costs in Case 15-E-0302 - Proceeding on Motion of the Commission to Implement a Large-Scale Renewable Program and a Clean Energy Standard, October 5, 2022.

  • BIOMASS

    Letter of Support for ReEnergy’s Petition concerning the development of a program that subsidizes bioenergy generation in Case 15-E-0302 - Proceeding on Motion of the Commission to Implement a Large-Scale Renewable Program and a Clean Energy Standard, September 28, 2022.

  • E-VALUE HYDRO PETITION

    Comments in support of the Petition of Interested Hydroelectric Parties Eligibility for Environmental Value Compensation for Pre-2015 Resources Under the Value of Distributed Energy Resources Tariff by ACE NY, Environmental Advocates, New Yorkers for Clean Power, Sierra Club, Northern Power and Light, NYSEIA, NY League of Conservation Voters, and NRDC in Case 15-E-0751 - Proceeding in the Matter of the Value of Distributed Energy Resources, August 29, 2022.

  • UTILITY-OWNED GENERATION

    Comments on the Notice Seeking Comment concerning the issue of utility ownership of DERs and large-scale renewable electric generation assets and questions by ACE NY and AEE in Case 22-M-0149 - Proceeding on Motion of the Commission Assessing Implementation of and Compliance with the Requirements and Targets of the Climate Leadership and Community Protection Act, August 11, 2022.

  • DATA SECURITY AGREEMENTS

    Comments on the Joint Utilities Petition to Modify the Data Security Agreement Self-Attestation Requirements and Implement a Governance Review Process for Regular Self-Attestation Updates by ACE NY, Advanced Energy Management Alliance, and AEE in Case 20-M-0082 - Proceeding on Motion of the Commission Regarding Strategic Use of Energy Related Data, July 25, 2022.

  • DISTRIBUTED SOLAR

    Joint Comments on the Staff Straw Proposal on Opt-out Community Distributed Generation, submitted by ACE NY, NRDC, New Yorkers for Clean Power, Environmental Advocates, and Sierra Club in Case 14-M-0224 – Proceeding on Motion of the Commission to Enable Community Choice Aggregation Programs, June 6, 2022.

  • EV CHARGING

    Joint Reply Comments on the Notice Soliciting Comments on a tariff to facilitate EV fast charging, submitted by ACE NY, Amply Power, CALSTART, ChargePoint, EVgo, Electrify America, Nikola Corporation, and Tesla, Inc. in CASE 22-E-0236 - Proceeding to Establish Alternatives to Traditional Demand-Based Rate Structures for Commercial Electric Vehicle Charging, June 6, 2022.

  • TRANSMISSION UPGRADES

    Comments on the Petition of Utilities Identifying Area of Concern Needs and Recommended Solutions, submitted by ACE NY in Case 20-E-0197 - Proceeding on Motion of the Commission to Implement Transmission Planning Pursuant to the Accelerated Renewable Energy Growth and Community Benefit Act, May 31, 2022.

  • EV CHARGING

    Joint Comments on the Notice Soliciting Comments on a tariff to facilitate faster EV charging in Case 22-E-0236 - Proceeding to Establish Alternatives to Traditional Demand-Based Rate Structures for Commercial Electric Vehicle Charging, May 25, 2022

  • EV CHARGING

    Comments on the Petition of ConEd to Modify its EV Make-Ready Program to Improve Service to Disadvantaged Communities and Development of Fast Chargers Cost Sharing and Recovery Agreement, submitted by ACE NY and AEE in Case 18-E-0138 - Proceeding on Motion of the Commission Regarding Electric Vehicle Supply Equipment and Infrastructure, May 16, 2022.

  • ENERGY EFFICIENCY

    Comments on the Petition of Consolidated Edison to Support Clean Heat Market Growth Through Transfer of Unspent and Previously Authorized Funding, submitted by ACE NY in Case 18-E-0084 - In the Matter of a Comprehensive Energy Efficiency Initiative, May 16, 2022.

  • TRANSMISSION UPGRADES

    Comments on the NYSEG Petition regarding Phase 1 local transmission system upgrades filed in Case 20-E-0197 - Proceeding on Motion of the Commission to Implement Transmission Planning Pursuant to the Accelerated Renewable Energy Growth and Community Benefit Act, March 27, 2022.

  • DISTRIBUTED SOLAR

    Comments on the 10 Gigawatt Distributed Solar Roadmap: Policy Options for the Continued Growth of Distributed Solar Whitepaper, submitted by ACE NY, SEIA, NYSEIA and CCSA in Case 21-E-0629 – In the Matter of the Advancement of Distributed Solar, March 7, 2022.

  • TRANSMISSION UPGRADES

    Comments on the Petition of Niagara Mohawk Power Corporation D/B/A National Grid for Cost Recovery of Phase 1 Local Transmission Projects, submitted by ACE NY in Case 20-E-0197 - Proceeding on Motion of the Commission to Implement Transmission Planning Pursuant to the Accelerated Renewable Energy Growth and Community Benefit Act, February 29, 2022.

  • TRANSMISSION UPGRADES

    Comments on the Cost Sharing and Recovery Agreement, submitted by ACE NY in Case 20-E-0197 - Proceeding on Motion of the Commission to Implement Transmission Planning Pursuant to the Accelerated Renewable Energy Growth and Community Benefit Act, February 8, 2022.

  • TIER 4 RENEWABLES

    Comments on the Petition Regarding Agreements for Procurement of Tier 4 Renewable Energy Certificates, submitted by ACE NY in Case 15-E-0302 - Proceeding on Motion of the Commission to Implement a Large-Scale Renewable Program and a Clean Energy Standard, February 7, 2022.

2021 and 2020 Filings at the Public Service Commission


  • October 26, 2021

    Letter to Chair Christian Regarding E-Value in VDER. Submitted by: SEIA, NYSEIA, NRDC, CCSA, Vote Solar, and ACE NY in Case 15-E-0751 - In the Matter of the Value of Distributed Energy Resources.

  • September 17, 2021

    Surreply Comments on Joint Utilities Allocated Cost of Service Proposal. Submitted by: ACE NY, and AEEI, NY-BEST, New York City, Multiple Intervenors, AEMA in Case 15-E-0751– On the Joint Utilities’ Alternative Proposal for an Allocated Cost of Service Methodology.

  • September 13, 2021

    Comments on Utilities’ Managed Charging Programs. Submitted by: ACE NY, and AEEI in Case 18-E-0138– On the Utilities’ Managed Charging Programs for the Electric Vehicle (EV) Infrastructure Make-Ready Programs

  • August 23, 2021

    Comments on Joint Petition for expanded Solar For All. Submitted by: ACE NY, NYSEIA, SEIA in Case 19-E-0735– On Petition filed by National Grid and NYSERDA to auto enroll customers into Expanded Solar for All program.

  • August 20, 2021

    Comments on Joint Utilities Allocated Cost of Service Proposal. Submitted by: ACE NY, and AEEI in Case 15-E-0751– On the Joint Utilities’ Alternative Proposal for an Allocated Cost of Service Methodology.

  • August 9, 2021

    Comments in response to the Petition for rehearing of Mission:data Coalition. Submitted by: ACE NY, AEE, AEMA in Case 20-M-0082– On Petition filed by Mission:data Coalition requesting rehearing on certain conditions in the Data Framework Order.

  • August 9, 2021

    ACE NY filed Comments on the Tier 2 Re-sale Implementation Plan Proposal Submitted by ACE NY in Case 15-E-0302.

  • June 22, 2021

    ACE NY filed Comments on the Staff Straw Proposal for Conducting Headroom Assessments in Case 20-E-0197. Submitted by ACE NY.

  • June 14, 2021

    Comments Regarding Customer Benefit Contribution Charges. Submitted by: ACE NY and AEE in Case 15-E-0751– On Petition Joint Utility Draft Tariff for Customer Benefit Contribution Charges.

  • May 28, 2021

    Comments in response to the Petition for rehearing of Mission:data Coalition. Submitted by: ACE NY, AEE, AEMA in Case 20-M-0082– On Petition filed by Mission:data Coalition requesting rehearing on certain conditions in the Data Framework Order.

  • May 19, 2021

    Comments on Staff Report on New York’s Energy Affordability Policy. Submitted by: ACE NY and AEE in Case 20-M-0266 – On select recommendations

  • April 5, 2021

    Comments on NYSERDA’s Petition Regarding Clean Energy Fund Triennial Review. Submitted by: ACE NY, NRDC, NYCP, TNC in Case 14-M-0094 – On Petition filed by NYSERDA Requesting Authorization to Optimize and Continue NYSERDA’s Clean Energy Fund (CEF) portfolio

  • April 2, 2021

    Comments on Exemptions for Utility Standby Rates. SUBMITTED BY: ACE NY in Request for Comments - Case 19-E-0079 - Standby Rate Exemption: Comments due on whether previously established temporary exemptions from standby rates for certain forms of distributed energy resources and efficient combined heat and power projects should be continued.

  • March 22, 2021

    Comments on Initial Report on the New York Power Grid Study. SUBMITTED BY: ACE NY, NYOWA, ACP, AEE in Case 20-E-0197 - Proceeding on Motion of the Commission to Implement Transmission Planning Pursuant to the Accelerated Renewable Energy Growth and Community Benefit Act

  • January 20, 2021

    Comments on Utility Transmission and Distribution Investment Working Group Report. SUBMITTED BY: ACE NY with AEE Institute, ACP, NRDC in CASE 20-E-0197 – Proceeding on Motion of the Commission to Implement Transmission Planning Pursuant to the Accelerated Renewable Energy Growth and Community Benefit Act

  • December 7, 2020

    Comments on Proposed Regulations for Permitting renewable energy projects. SUBMITTED BY: ACE NY with SEIA, ACPA, and NYSEIA for Draft Regulations Chapter XVIII Title 19 (Subparts 900-1 – 900-5; 900-7 – 900-15) Draft Regulations Chapter XVIII Title 19 (Subpart 900-6)

  • November 18, 2020

    Protest Of Clean Energy Parties Of Cricket Valley Energy Center LLC and Empire Generating Company, LLC V. NYISO. SUBMITTED BY: ACE NY with NRDC, ACPA, Sierra Club, and AEEI for FERC Docket No. EL21-7-000

  • September 20, 2020

    Comments of Clean Energy Parties Concerning Petitions for Priority Transmission Project Designations. SUBMITTED BY: NRDC and ACE NY for CASE 20-E-0197 – Proceeding on Motion of the Commission to Implement Transmission Planning Pursuant to the Accelerated Renewable Energy Growth and Community Benefit Act

  • August 24, 2020

    Initial Comments on Staff Whitepaper in Response to the June 30 Notice of Stakeholder Meeting and Soliciting of Comments. SUBMITTED BY: AEE on behalf of ACE NY and AEMA in Case 20-M-0082 – Proceeding on Motion of the Commission Regarding the Strategic Use of Energy Data

  • July 24, 2020

    Preliminary Comments: on the White Paper on Clean Energy Standard Procurements to Implement New York’s Climate Leadership and Community Protection Act, dated June 18, 2020, in response to the Notice Scheduling Technical Conference. SUBMITTED BY: AWEA, AEE Institute, and the SEIA in Case 15-E-0302 - Proceeding on Motion of the Commission to Implement a Large-Scale Renewable Program and a Clean Energy Standar

  • July 24, 2020

    SGEIS comments: regarding the Supplemental Generic Environmental Impact Statement (“SGEIS”) for the Climate Leadership and Community Protection Act. SUBMITTED BY: ACENY and NYOWA in Case 15-E-0302 - Proceeding on Motion of the Commission to Implement a Large-Scale Renewable Program and a Clean Energy Standard

  • July 13, 2020

    Comments Re: COVID-19 Impacts on Utility Service. SUBMITTED BY: ACE NY with AEEI in Case 20-M-0266: Proceeding Regarding the Effects of COVID-19 on Utility Service

  • July 3, 2020

    Filing in the Matter of a Renewable Energy Facility Host Community Benefit Program. SUBMITTED BY: ACE NY and the SEIA in Case 20-E-0249 - In the Matter of a Renewable Energy Facility Host Community Benefit Program, in response to the Notice Soliciting Comments issued May 28, 2020.

  • May 12, 2020

    Comments in Response to Regulations Implementing Article 10 of the Public Service Law—Definitions. Proposed Action: Amendment of Parts 1000 and 1001 of Title 16 NYCRR

  • May 4, 2020

    Comments in Response to Petition Regarding a Clean Energy Standard Competitive Tier 2 Program for Baseline Renewable Generation in Case 15-E-0302 - Proceeding on Motion of the Commission to Implement a Large-Scale Renewable Program and a Clean Energy Standard

  • May 4, 2020

    Petition of for an Order Granting Certificate of Public Convenience and Necessity Pursuant to Section 68 of the Public Service Law. SUBMITTED BY: NextEra Energy Transmission New York, Inc. in Case 18-E-0765 - Certificate of Public Convenience and Necessity - Original

  • April 27, 2020

    Comments on Staff Whitepaper on Regarding Electric Vehicle Supply Equipment and Infrastructure detailing a proposed statewide “Make-Ready Program”. SUBMITTED BY: ACE NY with AEE Institute in Case 18-E-0138 - Proceeding on Motion of the Commission Regarding Electric Vehicle Supply Equipment and Infrastructure.

  • April 9, 2020

    Letter on Granting COVID-19 Flexibility to Utility EE Programs. SUBMITTED BY: ACE NY in Case 18-M-0084 - In the Matter of a Comprehensive Energy Efficiency Initiative.

  • March 16, 2020

    Comments on the New York State Energy Research and Development Authority Petition Requesting Additional NY Sun Program Funding and Extension of Program Through 2025. SUBMITTED BY: Solar Energy Industries Association, ACE NY, Coalition for Community Solar Access, NRDC, New York Solar Energy Industries Association, the Pace Energy and Climate Center and Vote Solar in Matter 17-01277; Case 15-E-0751 - In the Matter of the Value of Distributed Energy Resources

  • February 24, 2020

    Comments on Staff Whitepaper on Rate Design for Mass Market Net Metering Successor Tariff issued December 9, 2019. SUBMITTED BY: Solar Energy Industries Association, ACE NY, Coalition for Community Solar Access, NRDC, the New York Solar Energy Industries Association, the Pace Energy and Climate Center, and Vote Solar in Matter 17-01277; Case 15-E-0751- In the Matter of the Value of Distributed Energy Resources Working Group Regarding Rate Design

  • February 10, 2020

    Comments on the New York State Energy Research and Development Authority Petition Requesting Additional NY Sun Program Funding and Extension of Program Through 2025. SUBMITTED BY: Solar Energy Industries Association, ACE NY, Coalition for Community Solar Access, NRDC, New York Solar Energy Industries Association, the Pace Energy and Climate Center and Vote Solar in Case 03-E-0188; Case 14-M-0094- Proceeding on Motion of the Commission Regarding a Retail Renewable Portfolio Standard. Proceeding on Motion of the Commission to Consider a Clean Energy Fund.

  • January 31, 2020

    Pursuant to the Notice Extending Reply Comment Deadline, submits for filing reply comments in response to the August 8 Order Instituting Proceeding and Soliciting Comments. SUBMITTED BY: AEE Institute on behalf of AEE, ACE NY, AWEA, and SEIA in Case 19-E-0530 - Proceeding on Motion of the Commission to Consider Resource Adequacy Matters Proceeding on Motion of the Commission to Implement a Large-Scale Renewable Program and a Clean Energy Standard.